ML19128A023

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Request for Additional Information: Susquehanna Steam Electric Station, Units 1 and 2 License Amendment Request for ESW Piping Replacement
ML19128A023
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 05/07/2019
From: Jennifer Tobin
Plant Licensing Branch 1
To: Cimorelli K
Susquehanna
Tobin J
References
EPID L-2019-LLA-0004
Download: ML19128A023 (2)


Text

From:

Tobin, Jennifer To:

Kevin.Cimorelli@TalenEnergy.com Cc:

Krick, Melisa; jason.jennings@talenenergy.com; Jurek, Shane; Hood, Tanya; Danna, James

Subject:

Request for Additional Information: Susquehanna Units 1 and 2 License Amendment Request for ESW Piping Replacement (EPID: L-2019-LLA-0004)

Date:

Tuesday, May 07, 2019 2:05:00 PM

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -

REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO REPLACE EMERGENCY SERVICE WATER PIPING (EPID: L-2019-LLA-0004)

By letter dated January 9, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19009A431), Susquehanna Nuclear, LLC (the licensee) submitted a license amendment request (LAR) for Susquehanna Steam Electric Station (Susquehanna), Units 1 and 2. The proposed amendment to permit one division of the Emergency Service Water System (ESW) and Residual Heat Removal Service Water (RHRSW) systems to be inoperable for a total of 14 days to address ESW piping replacement due to degradation.

The Nuclear Regulatory Commissions (NRC) staff is reviewing your submittal and has determined that additional information is needed to complete its review. The specific request for additional information (RAI) question is provided below. This question is being sent to ensure that it is understandable, the regulatory basis is clear, and to determine if the information was previously docketed. A clarification phone call was held May 7, 2019 and as a result, no changes were made to the draft RAI. This email will be made publicly available in ADAMS and a response is due in 30 days (by June 7, 2019) as per agreement at the clarification call.

If you have any questions regarding this matter, please contact me at 301-415-2328 or by e-mail.

Jenny Tobin Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2738 301-415-2328 Jennifer.Tobin@nrc.gov

REQUEST FOR ADDITIONAL INFORMATION SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 PROPOSED AMENDMENT TO LICENSES NPF-14 AND NPF-22 DOCKET NOS.: 50-387, AND 50-388 TEMPORARY CHANGE TO THE TECHNICAL SPECIFICATIONS TO ALLOW REPLACEMENT OF EMERGENCY SERVICE WATER SYSTEM PIPING, PLA-7751.

(EPID: L-2019-LLA-0004)

By letter dated January 9, 2019 (Agencywide Document Access and Management System (ADAMS) Accession Number ML19009A431, Talen Energy (the licensee) submitted a proposed amendment to permit one division of the Emergency Service Water System (ESW) and Residual Heat Removal Service Water (RHRSW) systems to be inoperable for

a total of 14 days to address ESW piping replacement due to degradation. Based on inspection results of the piping which is buried approximately 18 feet below grade outside the Unit 1 Reactor Building, Susquehanna will determine the appropriate scope for the other division and opposite unit pipe replacement.

10 CFR 50.36(c)(2) requires that, when an Limiting Conditions for Operation (LCO) of a nuclear reactor plant is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the condition can be met.

Susquehanna Technical Specifications (TSs) list remedial actions according to described Conditions in an ACTIONS table for each TS. Each Condition has Required Actions that must be completed within a given Completion Time (CT).

The licensee proposed a CT of 14 days for TS 3.7.1 Condition B and TS 3.7.2 Conditions B and C during the replacement of ESW piping for the opposite unit. The proposed CTs are modified by footnotes which identifies that the temporary extension is only applicable during the ESW piping replacement and will expire in 2026 for Unit 2 and 2027 for Unit 1.

In Enclosure 1 of the LAR, the licensee provided an evaluation of the proposed changes.

Section 3.3 of this enclosure contains a list of compensatory measures the licensee will implement during the evolution to replace the ESW piping. In Enclosure 5 of the LAR, the licensee made a regulatory commitment to implement the compensatory measures identified in Section 3.3 of Enclosure 1. It appears that part of the justification for the proposed temporary CTs relies on the compensatory measures in Section 3.3.

Provide justification for the proposed CT language and footnote language that does not mention the compensatory measures. Alternatively, consider rewording the proposed CT language and footnote language to indicate that the 14 day CT is contingent on implementation of the compensatory measures in Section 3.3 of Enclosure 1 to the LAR.